Lone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

Page 1 March 2 4th , 2015

Danielle M. Rivera, CEO Lone Star Sky Solutions , LLC 1699 Ridge Runner Ct. Clarksville, TN 37042 danielle@lonestarskyllc.com (931) 444

- 7150

U.S. Department of Transportation

Docket Management System 1200 New Jersey Ave., SE Washington, DC 205930

Petition for Exemption Filed under Section 333 of the 2012 FAA Modernization and Reform Act

Filed via www.regulations.gov

Dear FAA UAS E xemption R eview T eam
,

Lone Star Sky Solutions, LLC (“LSSS”) is respectfully writing to request exemption s that would

lead to safe and legal entry into the NAS under Section 333 of the FAA Modernization and

Reform Act of 2012

. A g ranted exemption would allow us to o btain a COA , if required, to conduct commercial operations and training described in t his letter. Furthermore, it would

enhance airspace safety and efficiency in our community by offering affordable aerial imagery, video, and surveying to the general public that would deter and mitigate unsafe and illegal entrance into the NAS by untrained and unlicensed UAS users

.

Annex A outlines requested exemptions and applicable reasoning

. Annex B briefly describes PIC training program and qualif ications . Annex C outlines operations, safety considerations, and

limitations. Th e remainder of this letter is outlined in accordance with (“IAW”) the Section 333

Guidance document available at FAA’s Petitioning for Exemption under Section 333

.

LSSS’ UAS Platforms

1. Operations will be conducted with 3D Robotics’ X8+ and SenseFly’s eBee UAS(s). Design and operational characteristics are defined within attached manuals. Recently, exemptions for the X8+ were granted to Build Imagery, BNSF Railway Company, and the eBee to Quiet Creek Corporation , amongst others, on th e 11th and 12 th of Marc h. In addition, airworthiness of both platforms has been demonstrated in different projects

with in the United States (e.g., eBee by New Mexico State University

, X8 ).Lone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

Page 2 2. PIC(s) will be trained on and operate by strict conditions defined by the Safety Program of the Academy of Model Aeronaut ics

, attached flight manuals , and LSSS’ training

program

. Inspections will be conducted before each flight IAW platform’s respective

checklist and Annex C . Maintenance and repairs will be performed IAW 3DR or eBee

u ser manual , at minimum, quarterly or upon failed pre

- or post

- flight inspections.

3. All equipment , frequencies, and payloads compl y with FCC requirements and can be furnished upon request.

LSSS’ PIC(s)

4. LSSS has developed a PIC training program that can be furnished upon request . Refer

to Annex B for further information

.

5. All PIC(s) will obtain and maintain First Aid and CPR certification. They will be able to apply basic aid in the unlikely situation that a n UAS collide s with personnel.

Operation of UAS

6. LSSS conducts operations to provide affordable aerial photography, video, and surveying to the general public

. Refer to Annex C for a list of operations, safety considerations, and limitations.

7. The X8+ max operating speed will not exceed 15MPH and the eBee will not exceed

35MPH . Neither platform will exceed an altitude of 400 feet above ground level. Both platforms will not operate at night or in weather conditions that produce precipitation,

vis ibility less than three miles from the launch point

, c eilings less than 1000 feet, sustained winds greater than 25 knots, or gust spreads greater than 10 knots. All PIC(s) are equipped with Kestrel s to measure current site wind speed. This will prevent

unnec essary risk to people and property

.

8. Areas of intended operations are defined by property owner s , responsible agent s , or government agencies consent and boundaries obtained by government GIS sources

. Refer to Annex C for further inf ormation.

9. PIC(s) will not conduct operations within five nautical miles of airports without approved consent from base operations or air traffic control authorities. PIC(s) will notify these agencies at least 72 hours prior if operation site is within fiv e nautical miles of an airport.

10. PIC(s) will maintain unaided VLOS with UAS. In complex duties or terrain, VO(s) will

be used to maintain VLOS with UAS and PIC , and relay flight information

.Lone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

Page 3 11. PIC(s) will verify flight limiting factors upon arrival to the operation site by using government sources and Kestrel for weather data, surveying and documenting site hazards, and conduct ing pre

- flight inspections prior to operations.

12. PIC(s) , when applicable to operations, will submit FAA Form 7711

- 1 or equivalent

fo rm with Flight Standards District Office at least 72 hours prior operations.

13. Will obtain COA , if required, from FAA Air Traffic Organization if granted exemption.

We hope that you grant us an exemption to the current regulations. We are looking forward t o leading the way and setting a safe and efficient standard for future companies and UAS operators. Thank you for your consideration.

Very respectfully,

DANIELLE M. RIVERA, CEO LONE STAR SKY SOLUTIONS, LLCLone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

Page 4 ANNEX A : Requested Exemptions

- Part 61 Certification

o 61.113 (a, b)

 O perators should not be required to hold a commercial or private pilot licenses given safety features of X8+, eBee, AMA training, Lone Star Sky Solutions’ training program, and safety measures described in Annex C

.

- Part 91 General Operating and Flight Rules

o 91.105

o 91.109

 Flight instruction will be accomplished using a thorough and safe training

program outlined in Annex B

.

o 91.119 (c)

 Cannot operate above 400 feet AGL and therefore cannot comply with this regulation.

o 91.121

 O nboard systems of the eBee and X8+ provide a similar level of safety by using GPS and other orientation sensors.

o 91.151 (a)

 X8+ and eBee do not use fuel. However, operators will p repare to land

when batter y falls below 25% and before 20% is reached. PIC(s) will conduct a weather brief before each flight and UAS will not be operated

below VFR conditions.

o 91.405 (a)

, 91.407 (a)(1)

, 91.409 (a)(1, 2)

, 91.417 (a, b)

 All maintenance and repairs will be accomplished by utilizing 3DR documentation or eBee user manual. An equivalent level of safety to the regulations will be achieved because the X8+ and eBee are not complex mechanical devices. Furthermore, pre

- and post

- flig ht checks will be conducted with each flight. If deficiencies are found, the UAS will not be operated until repairs are conducted. All repairs will be logged.

o 91.7 (a)

 Airworthiness of both aircraft has been demonstrated. If required, a waiver or certificate according to step four on the Petitioning for Exemption

under Sectio n 333 web page will be obtained

.

o 91.203 (a, b), 91.9

 An equivalent level of safety will be ensured by requiring PIC(s) to carry manuals and standard operating procedure documents while operating

UAS.

In addition, request exemption from other regulations deemed necessary by reviewer.Lone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

Page 5 ANNEX B: Pilot in Command Qualifications

Lone Star Sky Solutions’ training program is developed by our co

- founder who has extensive knowledge in small UAS military applications and safety programs. T he program is designed with community safety at mind using AMA guidelines

. Ultimately, t his program will efficient ly qualify trainees to operate and recognize the need for PIC refresher training.

The program separate s operators in to three tiers: Trainee, Basic Mission Qualified (“BMQ”) and Fully Mission Qualified (“FMQ”) PIC (s)

. Minimum q ualification s are listed below.

1. Trainee : Can only operate UAS on training courses under supervision

. Primary goal

is to reach BMQ status by complet ing classroom, visual observer (“VO”) , and operational instruction.

a. Possess valid state issued driver’s license

b. Passes LSSS interview

c. Passes background check

2. BMQ PIC: Can operate UAS under supervision . Primary goal is to reach FMQ status by acquiring supervised on

- the

- job flight hours, pass ing check

- ride, and becoming

First Aid and CPR certificated

.

a. Complete s eight hours of classroom instruction

b. Completes four hours of simulated flight training

c. Complete s at least eight hours of ope ration instruction per platform

d. Complete s at least eight hours o f VO on

- the

- job training

3. FMQ PIC: Can operate UAS unsupervised and can recommend trainee upgrade or BMQ downgrade.

a. Complete s at least tw elve hours of supervised on

- the

- job flight

b. Passe s written test

c. Passe s UAS platform check

- ride course

d. Receives Basic First Aid and CPR certificationLone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

Page 6 ANNEX C: Operations, Safety and Limitations

Lone Star Sky Solutions (“LSSS”) conducts several types of operations for two primary reasons. First, is to provide affordable aerial photography, video, and surveying to the ge neral public. Second, is to provide free education and training to youth, high

- school, and undergraduates in

the re freshman or sophomore year. By providing affordable services to the general public and

free education

, we hope to keep the community safe by deterring and mitigating untrained and unlicensed UAS users from entering the NAS.

1. Proposed operations are, but not inclusive to , the following:

a. Employee and youth training on LSSS’ properties or approved public locations

with written consent of r esponsible government authority

b. Real

- estate photography and video services for property owners
, managers, or real

- estate agents

c. Home inspections with multi

- spectral cameras for owners or potential buyers.

d. Outdoor event photography or video (e.g., weddings, golf tournament, etc.) for the general public with consent of property owners and or r esponsible government authority

e. Agriculture monitoring, imagery, and surveying for owners, farmers, or agronomist wi th permission of property owner

f. General imagery, mapping, and surveying for property/land owners or governments

2. Safety is important, and the guidelines below will be followed in accordance with (“IAW”) FAA regulations.

a. Pre

- flight : i. PIC(s) will define operational borde rs using government GIS sources

ii. PIC(s ) will account for all persons on property.

iii. PIC(s) will seek consent for persons withi n 100 feet of flight operations

iv. PIC(s) will survey a nd document site flight hazards

v. PIC(s) will review weather data from Kestrel and government sources

vi. PIC(s) will verify payload limits are not exceeded

vii. PIC(s) will conduct specific platform pre

- flight checklist

viii. PIC(s) will document all tasks

ix. PIC(s) will conduct brief ings for all PIC(s), VO(s), owners or responsible agent, and persons within 100 feet of operations. Brief wi ll highlight the concept of operation, potential hazards, weather conditions, and abbreviated guidelines of the Academy o f Model Aeronautics Safety Code

b. Flight Operations and Limitations : i. PIC(s) will operate according to FAA regulations, m anuals , and standard operating procedures

ii. PIC(s) will end operations before sunset.

iii. PIC(s) will leave operation site before evening civil twilight.Lone Star Sky Solutions, LLC. Section 333 UAS Exemption Request

Page 7 iv. PIC(s) will not arrive to operation site before morning civil twilight.

v. PIC(s) will not start operations before sunrise.

vi. PIC(s) will not operate o n any property without consent from owner or responsible agent

vii. PIC(s) will not fly within 5NM of airports without consent from base operations or a ir traffic control authorities

viii. PIC(s) will not fly over people

ix. PIC(s) will not fly within 100 feet of non

- consenting persons

x. PIC(s) will not fly in excess of 400 feet above ground level

xi. PIC(s) will not operate UAS, to include payloads

, more than 20 pounds

xii. PIC(s) will maintain VLOS and or coordination with VO( s)

xiii. PIC(s) will prepare for landing when batter y level falls below 25% an d

land before level reaches 20%

c. Supervision of Operations

i. FMQ PIC(s) will ensure personnel within 100 feet of UAS operations are wearing protective equipment (e.g., safety vest and glasses, hard hat, etc.)

ii. FMQ PIC(s) will ensure all FAA UAS regulations and guidelines are

maintained.

iii. FMQ PIC(s) will document violations by trainees, VO(s), or BMQ(s)

iv. FMQ PIC(s) will recommend upgrade and downgrade of trainees or BMQ(s)

v. FMQ PIC(s) will conduct spot checks to ensure l ead PIC gained proper

consent from all authorities.